OSHA has revised the construction standard for electric power line work to make it more consistent with the corresponding general industry standard and is also making some revisions to both the construction and general industry requirements. The final rule includes new or revised requirements for fall protection, minimum approach distances, and arc-flash protection, and for host employers and contract employers to exchange safety-related information. The final rule also includes requirements for electrical protective equipment. The final rule was to become effective on July 10, 2014. However, OSHA adopted delayed compliance deadlines for certain requirements and established this temporary enforcement policy that is in effect through February 17, 2015. OSHA posted the regulatory text from the final rule on July 10, 2014. Employers can access the regulatory text from the prior version of 29 CFR 1910.269 here.

In a previous article I posted the Fire Watch requirements found in OSHA, NFPA, and some state Fire Codes; however, the one critical path that is high on our list of findings during audits is the method of extinguishing the fire watch is provided. We have, on many occasions, found fire extinguishers that had not been inspected in months, some were years past due for their annual maintenance/inspection, some were just dead and even once or twice we found the extinguisher to actually be EMPTY. These are easy findings that do not get any push back; however, when we mention the size or type extinguisher may not be suitable for the size of HW job there is usually much debate. We have seen "kitchen extinguishers" which are nothing more than a pressure can being used on jobs with multiple HW tasks taking place. Bottom line, the extinguisher needs to be rated for the level of risks associated with its intended use. I have always suggested nothing less than a 10 pound ABC Dry Chemical extinguisher and a "20 pounder" is even better, but in some cases, such as the OH Fire Code, there are some SPECIFIC requirements... (but you will see why I always suggest at least a 10 lb, with hopes they will use a 20 lb'er, ABC to my PSM/RMP clients)

Fire watches are usually the youngest and lowest paid crew member on the job. But why is this? After all they are the difference between a job done safely and the potential loss of an entire business. Most people think hotwork fires are rare - and they would be WRONG! Anyone who subscribes to my incident alerts can tell you that each week I report two or three significant hotwork fires. And even then, I am only reporting those that are significant enough to make the news and I only report those that are industrially related. Anyone can do a Google search and see there are dozens of Hot Work incidents each week that displace hundreds of residents from their homes and I do not list those where a family member was using a torch to kill weeds or thaw pipes. But this article is meant to settle the debate as to when is a fire watch actually required. Here is what OSHA, NFPA, and IFC state:

In just about all our audits we get this question. We all know that OSHA requires us to maintain our PRCS Entry Permits for one year so that they can be used in our annual program review; but they make no mention of HW permit retention. We always advise to maintain HW permits on a rolling 12 month schedule; however, at some very large facilities this can take a lot of filing cabinets! So I am asked by legal "what is officially required" and that is where I go to one of my most trusted sources... State Fire Code. I am not aware of any state not having a fire code, even when most just adopt the International Fire Code(s). For example, in my home state of Ohio we are REQUIRED by our code to keep our hotwork permits for....

The targeted inspection, which began October 2014, is part of OSHA's National Emphasis Program on chemicals, and focuses on OSHA's PSM standard. The pork-processing facility operates two anhydrous ammonia refrigeration systems. OSHA issued seven serious citations related to the process safety management of the ammonia refrigeration systems used in its production process. Three violations are being cited for fall, electrical and machine guarding hazards. Here is a breakdown of the citations:

For the life of me I can not figure out the aversion to doing MOCs. I am guessing that my experiences in Petrochem were not the norm, as we used our MOC process for just about everything under the sun. Heck even the QC group used our MOC process. We rarely questioned the value of doing an MOC and the MOC process was fully accepted as a way of managing changes irregardless of what OSHA or EPA required. As such I saw many occasions where the MOC process saved my behind; especially in my early days as a safety manager doing PSM. Here are some of my learning's…

I found this latest Letter of Interpretation regarding PSM Battery Limits an interesting read. The scenario is VERY COMMON and I am so glad OSHA wrote this letter! OSHA reminds us that cylinders stored in the same fire area (e.g. a fire has no passive control(s) to prevent its spread) that ALL of the cylinders that could be impacted by the same fire MUST BE AGGREGATED to determine if the threshold has been exceeded. NOTE: the person asking the question appears to be wanting to lay claim that each individual cylinder (DOT 3AA-2400) will be adequate "separation". This letter hits the following key topics:

Respondent is a corporation organized under the laws of the State of Michigan, and is thus a "person" according to section 302(e) of the CAA. At all times relevant to this Complaint, Respondent owned, operated, controlled and supervised a facility which includes buildings, structures, equipment, and installations belonging to the same industrial group, located on one or more contiguous properties and under the control of Respondent. The facility manufactures solid craft foam for the floral industry and others. Respondent uses butane, difluoroethane and pentane in its manufacturing processes. Respondent's facility had butane, since November 2011, difluoroethane since November 2011, and pentane since May 2013, each in quantities exceeding 10,000 pounds through 2013. Respondent thus maintained certain regulated substances at its facility at certain times in quantities exceeding the thresholds under the Chemical Accident Pollution Prevention rule. Respondent's processes at its facility subject it to Program 3 requirements because the distance to public receptors, as defined at 40 C.F .R. § 68.30, is less than the distance to the flammable or toxic endpoint for a worst-case release assessment under 40 C.F.R. § 68.25, and because the processes are subject to the process safety management standard at 29 C.F.R. § 1910.119.

Employees risked potentially lethal suffocation caused by dangerous fumes as the company did not test the atmosphere and properly ventilate the air in food transport tankers before allowing workers to enter. After receiving an employee complaint, OSHA initiated an investigation on Aug. 6, 2014, at the tank-cleaning facility. The agency issued two willful and six serious safety violations involving permit-required confined spaces and fall hazards. The agency proposed fines of $179,000. OSHA's investigation found that the facility did not ventilate the tankers to eliminate and control atmospheric hazards and failed to test and monitor the atmospheric conditions in the tankers before allowing workers to enter and clean them. Employees were also exposed to fall hazards of nearly 11 feet while cleaning the tankers, resulting in the issuance of the two willful violations. OSHA regulations require that the atmosphere in a confined space must be tested for oxygen, combustible gases, toxic gases and vapors. A confined space is one large enough for workers to enter and perform certain jobs, such as cleaning a food transport tanker, but it has limited or restricted means for entry or exit and is not designed for continuous occupancy. The agency determined that the facility failed to develop a confined space entry permit program to include training workers on hazards, procedures for summoning emergency services and providing monitors when an employee entered a confined space. Electrical safety violations were also noted. A total of six serious citations were issued for these violations. Here is a breakdown of the citations: